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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />0 <br />leaks and be vapor tight in that vapor check valves were leaking <br />on November 8, 1985 as set forth in Exhibit 2 at #22. <br />FOURTH CAUSE OF ACTION <br />(UNLAWFUL BUSINESS PRACTICES) <br />ACTIONS FOR CIVIL PENALTIES FOR UNLAWFUL BUSINESS <br />PRACTICES IN VIOLATION OF §517200-17208 OF THE <br />BUSINESS AND PROFESSIONS COM RV vrnr.ATTUc TUR <br />ACT <br />041M <br />28. The People reallege and incorporate by reference <br />paragraphs 1 through 27. <br />29. Plaintiff is informed and believes and therefore alleges <br />that, beginning on an unknown date, but at least within the three <br />years prior to the filing of this complaint, and continuing to the <br />present, defendants, and each of them, have knowingly and <br />repeatedly engaged in conduct, and continue to engage in conduct <br />by agents, employees, officers, or directors of ST SERVICES <br />which is unlawful. Such repeated violations of California law <br />constitute unfair competition within the meaning of Business and <br />Professions Code Section 17200, which, in part, defines unfair <br />competition as any "unlawful, unfair, or fraudulent business <br />practice." Defendants' acts of unfair competition include, but <br />are not necessarily limited to, the following: <br />a) Violations of the Hazardous Waste Control Act: <br />Defendants,committ acts prohibited by the Act <br />as more particularly alleged in Paragraph 15 and <br />15a of this complaint, incorporated herein by <br />reference as if set forth in full herein. <br />13. <br />